Disciplinary Counsel v. Friedman

114 Ohio St. 3d 1 (2007) · Supreme Court of Ohio · June 6, 2007

Summary

The Ohio Supreme Court found that attorney Benjamin Stuart Friedman committed professional misconduct in connection with multiple divorce, dissolution, custody, and related client matters. The misconduct included neglect, misrepresentation, mishandling and failure to refund client funds, inadequate recordkeeping, and practicing law while suspended for failure to register. The court imposed a two-year suspension, with the final six months stayed subject to conditions including continued treatment, restitution, and no further misconduct.

Court
Supreme Court of Ohio
Writing for the Court
Moyer, C.J.; Pfeifer; Lundberg Stratton; O’Connor; O’Donnell; Lanzinger; Cupp
Jurisdiction
Ohio
Decision date
June 6, 2007
Procedural posture
Attorney-discipline proceeding in which Disciplinary Counsel charged respondent with professional misconduct. A hearing panel and the Board of Commissioners on Grievances and Discipline found violations and recommended a two-year suspension with the final six months stayed on conditions; the Supreme Court of Ohio adopted the findings and sanction.
Standard of review
The court independently reviewed the board's report and the record and determined that respondent violated the charged disciplinary provisions and that the recommended sanction was appropriate.
Precedential value
Published Ohio Supreme Court disciplinary decision; precedential as to the adjudicated misconduct and sanction.
Parties
Disciplinary Counsel v. Benjamin Stuart Friedman
Disposition
other

Topics

family law procedurefamily lawdivorcedissolution of marriageqdro

Practice areas

legal ethics and professional responsibilityattorney disciplinefamily law

Questions Presented

  1. Whether respondent violated the charged Ohio disciplinary rules through neglect of client matters, dishonesty and misrepresentation, improper fee practices, failure to return unearned fees and client funds, trust-account violations, and conduct prejudicial to the administration of justice.
  2. Whether respondent violated Ohio's attorney-registration rules by practicing law while his license was suspended.
  3. What sanction was appropriate for respondent's multiple disciplinary violations in light of the aggravating and mitigating factors.

Holdings

  1. Respondent violated all of the disciplinary provisions found by the board, including rules prohibiting dishonesty, conduct adversely reflecting on fitness to practice, excessive fees, failure to return unearned fees or client funds, neglect of entrusted matters, trust-account violations, conduct prejudicial to the administration of justice, and unauthorized practice during suspension.
  2. A two-year suspension from the practice of law, with the final six months stayed on specified conditions, was the appropriate sanction.

Key quotations

After weighing the aggravating and mitigating factors in this case, we agree with the parties and the board that respondent should be suspended from the practice of law for two years, with the final six months of that suspension stayed on conditions. (¶ 60)
A two-year suspension with the final six months stayed will appropriately protect the public, provided that respondent continues his daily efforts at maintaining sobriety. (¶ 61)

Factual background

Respondent represented multiple clients in custody, divorce, dissolution, and related matters, but repeatedly neglected their cases, failed to communicate, made false statements about filings and refunds, failed to return unearned fees promptly, mishandled client funds, and failed to provide required accountings. In one matter, he incorrectly prepared a QDRO, causing financial consequences to the client. Respondent also practiced law while his license was summarily suspended for failing to comply with attorney-registration requirements.

Procedural history

Relator filed an amended disciplinary complaint on April 21, 2006. After a September 2006 hearing, the panel issued findings, conclusions, and a recommended sanction, which the board adopted. Respondent filed no objections, and the Supreme Court of Ohio reviewed and adopted the board's findings and recommended sanction.

Court Document

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